Pinnacle Madison Avenue Corporation v. Italian Trade Agency (ITA)
| Pinnacle Madison Avenue Corporation |
| Italian Trade Commission and Italian Trade Agency (ITA) |
| 1:2022cv03841 |
| May 11, 2022 |
| US District Court for the Southern District of New York |
| Sarah L Cave |
| Analisa Torres |
| Torts to Land |
| 28 U.S.C. § 1446 nr Notice of Removal |
| None |
Docket Report
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Filing 25
ORDER, ITA shall file its sur-reply by Tuesday, July 12, 2022. SO ORDERED. ( Surreplies due by 7/12/2022.) (Signed by Magistrate Judge Sarah L Cave on 6/29/22) (yv)
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| Filing 24 LETTER addressed to Magistrate Judge Sarah L. Cave from Eddy Salcedo dated June 28, 2022 re: The Court's June 27, 2022 Scheduling Order. (DKT No. 23). Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
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Filing 23
ORDER granting #22 Letter Motion for Extension of Time to File Response/Reply re #22 FIRST LETTER MOTION for Extension of Time to File Response/Reply addressed to Magistrate Judge Sarah L. Cave from Luca Melchionna dated 06/26/2022. Respondent's motion-letter seeking an extension of time to respond to Petitioner's Reply Memorandum, Answer to Counterclaims, and the Reply Affidavits (ECF No. 22) is GRANTED, and the proposed deadline is ADOPTED. The Clerk of Court is respectfully directed to close ECF No. 22. SO ORDERED. (Signed by Magistrate Judge Sarah L Cave on 6/27/22) (yv)
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| Filing 22 FIRST LETTER MOTION for Extension of Time to File Response/Reply addressed to Magistrate Judge Sarah L. Cave from Luca Melchionna dated 06/26/2022. Document filed by Italian Trade Agency (ITA). Return Date set for 7/18/2022 at 07:00 PM..(Melchionna, Luca) |
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Filing 21
ORDER OF REFERENCE TO A MAGISTRATE JUDGE. Order that case be referred to the Clerk of Court for assignment to a Magistrate Judge for General Pretrial (includes scheduling, discovery, non-dispositive pretrial motions, and settlement). Referred to Magistrate Judge Sarah L Cave. (Signed by Judge Analisa Torres on 6/24/2022) (kv)
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| Filing 20 RESPONSE re: #10 Response,,,,,,,,, / Petitioner's Answer to Respondent's Counterclaims. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 19 REPLY re: #1 Notice of Removal,,,,, Reply Declaration of Eddy Salcedo, Esq. in Further Support of Petitioner's Order to Show Cause for Relief. Document filed by Pinnacle Madison Avenue Corporation. (Attachments: #1 Exhibit A- SOE drawings, #2 Exhibit B- Permit - SOE, #3 Exhibit C- DOB rescission of SWO).(Salcedo, Eddy) |
| Filing 18 REPLY re: #1 Notice of Removal,,,,, ., DECLARATION of Eddy Salcedo, Esq. in Support. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 17 RULE 7.1 CORPORATE DISCLOSURE STATEMENT. No Corporate Parent. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 16 REPLY MEMORANDUM OF LAW in Support re: #1 Notice of Removal,,,,, / Petitioner's Application for Relief Pursuant to Real Property Actions and Proceedings Law Section 881. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 15 REPLY AFFIDAVIT of Bruno Caligara in Support re: #1 Notice of Removal,,,,,. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 14 REPLY AFFIDAVIT of Ed Tostanoski in Support re: #1 Notice of Removal,,,,,. Document filed by Pinnacle Madison Avenue Corporation. (Attachments: #1 Exhibit A - Partial SWO issued by DOB on April 26, 2022, #2 Exhibit B - DOB's Stop Work Rescine Order dated May 17, 2022, #3 Exhibit C - Permit for the Alt-1 Work).(Salcedo, Eddy) |
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Filing 13
MEMO ENDORSEMENT on re: #12 Letter filed by Pinnacle Madison Avenue Corporation. ENDORSEMENT: By June 6, 2022, Petitioner shall file its reply. By June 21, 2022, Petitioner shall file its response to Respondent's counterclaims. SO ORDERED. (Responses due by 6/21/2022, Replies due by 6/6/2022.) (Signed by Judge Analisa Torres on 5/20/2022) (kv)
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| Filing 12 LETTER addressed to Judge Analisa Torres from Eddy Salcedo dated May 19, 2022 re: Requesting a Scheduling Order. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 11 RESPONSE re: #10 Response,,,,,,,,, #1 Notice of Removal,,,,, Memorandum of Law in Support of Opposition to Petition. Document filed by Italian Trade Agency (ITA)..(Melchionna, Luca) |
| Filing 10 RESPONSE re: #1 Notice of Removal,,,,, Opposition to Petition. Document filed by Italian Trade Agency (ITA). (Attachments: #1 Exhibit Exhibit 1 Pinnacle application cover to the LPC with no date, #2 Exhibit Exhibit 2 - Community Board 8 Resolution June 19 2020, #3 Exhibit Exhibit 3 - Pinnacles architect presentation dated June 15 2020 to Community Board 8, #4 Exhibit Exhibit 4 - Community Board 8 Resolution September 22 2020., #5 Exhibit Exhibit 5 - Friends resolution December 15 2020., #6 Exhibit Exhibit 6 - Historical picture of Auchinloss Townhouse, #7 Exhibit Exhibit 7 - July 8 2021 letter from Wendrowski, #8 Exhibit Exhibit 8 - Draft Construction Access License Agreement V.8-4-2021, #9 Exhibit Exhibit 9 - E-mail dated August 4 2021, #10 Exhibit Exhibit 10 - Draft License agreement V9-2-2021, #11 Exhibit Exhibit 11 E-mail dated 9-3-2021 from W. Wendrowski, #12 Exhibit Exhibit 12 E-mail dated 9-24-2021 from L. Melchionna, #13 Exhibit Exhibit 13 E-mail dated 9-8-2021 from Wendrowski, #14 Exhibit Exhibit 14 E-mail dated 9-23-2021 from Wendrowski, #15 Exhibit Exhibit 15 E-mail dated 10-11-2021 from Luca Melchionna, #16 Exhibit Exhibit 16 E-mail dated 10-12-2021 from Wendrowski, #17 Exhibit Exhibit 17 - Memo from K. Hirschberg 10-18-2021, #18 Exhibit Exhibit 18 - Memo from Donald Freedman 10-18-2021, #19 Exhibit Exhibit 19 E-mail dated 10-22-2021 from W. Wendrowski, #20 Exhibit Exhibit 20 - Answers from Pinnacle team 10-22-2021, #21 Exhibit Exhibit 21 - COFA 21-08247, #22 Exhibit Exhibit 22 E-mail dated 3-11-2022 from W. Wendrowski, #23 Exhibit Exhibit 23 - Letter from Vanguard 3-17-2022, #24 Exhibit Exhibit 24 - Stop Work Order 35651905L, #25 Exhibit Exhibit 25 - Pictures taken on or around May 13 2022, #26 Exhibit Exhibit 26 - Donald Freedman Affidavit May 16 2022, #27 Exhibit Exhibit 27 - Roberta Gratz Affidavit, #28 Exhibit Exhibit 28 - Andrew Dolkart Affidavit, #29 Exhibit Exhibit 29 - Kurt Hirschberg Affidavit, #30 Exhibit Exhibit 30 - Steven Knobel Affidavit, #31 Exhibit Exhibit 31 - Brad Rabinowitz Affidavit, #32 Exhibit Exhibit 32 - Evidence of Pictet business relationship with NYC, #33 Exhibit Exhibit 33 - DOB Violations summary).(Melchionna, Luca) |
| Filing 9 LETTER addressed to Judge Analisa Torres from Luca Melchionna dated May 29 2022 re: Exhibits not accepted by the system. Document filed by Italian Trade Agency (ITA)..(Melchionna, Luca) |
| Filing 8 FILING ERROR - DEFICIENT DOCKET ENTRY - FILER ERROR -(SEE #11) OPPOSITION BRIEF . Document filed by Italian Trade Agency (ITA)..(Melchionna, Luca) Modified on 5/19/2022 (kj). |
| Filing 7 FILING ERROR - DEFICIENT DOCKET ENTRY - FILER ERROR -(SEE #10) OPPOSITION BRIEF . Document filed by Italian Trade Agency (ITA)..(Melchionna, Luca) Modified on 5/19/2022 (kj). |
| Filing 6 LETTER addressed to Judge Analisa Torres from Luca Melchionna dated May 18, 2022 re: Today's filing. Document filed by Italian Trade Agency (ITA)..(Melchionna, Luca) |
| Filing 5 LETTER addressed to Judge Analisa Torres from Eddy Salcedo dated May 18, 2022 re: response to the Court's email, dated May 17, 2022, asking whether Petitioner intends to object to the removal of this matter to federal court. Document filed by Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 4 NOTICE OF APPEARANCE by Eddy Salcedo on behalf of Pinnacle Madison Avenue Corporation..(Salcedo, Eddy) |
| Filing 3 CIVIL COVER SHEET filed..(Melchionna, Luca) |
| Filing 2 FILING ERROR - PDF ERROR - CIVIL COVER SHEET filed..(Melchionna, Luca) Modified on 5/12/2022 (vf). |
| ***NOTICE TO ATTORNEY REGARDING DEFICIENT CIVIL COVER SHEET. Notice to attorney Luca Cm Melchionna to RE-FILE Document No. #2 Civil Cover Sheet. The filing is deficient for the following reason(s): Nature of Suit Error. Multiple Nature of suits selected on Form. Place an [X] in one box only. Re-file the document using the event type Civil Cover Sheet found under the event list Other Documents and attach the correct PDF. (vf) |
| ***NOTICE TO ATTORNEY TO ELECTRONICALLY FILE CIVIL COVER SHEET. Notice to Attorney Luca Cm Melchionna. Attorney must electronically file the Civil Cover Sheet. Use the event type Civil Cover Sheet found under the event list Other Documents. (vf) |
| ***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Luca Cm Melchionna. The party information for the following party/parties has been modified: Italian Trade Commission. The information for the party/parties has been modified for the following reason/reasons: party text was omitted; party name entered incorrectly. (vf) |
| Magistrate Judge Sarah L. Cave is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #https://nysd.uscourts.gov/sites/default/files/2018-06/AO-3.pdf. (vf) |
| Case Designated ECF. (vf) |
| CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Analisa Torres. Please download and review the Individual Practices of the assigned District Judge, located at #https://nysd.uscourts.gov/judges/district-judges. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #https://nysd.uscourts.gov/rules/ecf-related-instructions..(vf) |
| ***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Luca Cm Melchionna. The following case opening statistical information was erroneously selected/entered: Nature of Suit code 290 (Real Property: Other). The following correction(s) have been made to your case entry: the Nature of Suit code has been modified to 240 (Torts to Land). (vf) |
| Filing 1 NOTICE OF REMOVAL from New York Supreme Court, County of New York. Case Number: 152785/2022. (Filing Fee $ 402.00).Document filed by Italian Trade Agency (ITA). (Attachments: #1 Exhibit Tablo of Content, #2 Exhibit Verified Petition RPALP881, #3 Exhibit Affidavit JS Tarella, #4 Exhibit LPC COFA 11-16-21, #5 Exhibit LPC - Electronic approval 11-16-21, #6 Exhibit DOB Permit #M00640497-I1-SF, #7 Exhibit DOB Permit #M00640492-I1-SF, #8 Exhibit DOB Permit #M00670256-I1-GC, #9 Exhibit DOB Permit #M00670256-I1-FO, #10 Exhibit DOB Permit #M00670256-I1-ST, #11 Exhibit DOB Permit #M00682866-I1-PM, #12 Exhibit Affidavit Ed Tostanoski, #13 Exhibit Park Construction Group, Submittal #2977-2, #14 Exhibit Affidavit Craig Senior, #15 Exhibit SR SAFETY Site Safety Plan 6-22-2021, #16 Exhibit Affidavit Wendy T Wendrowski, #17 Exhibit Letter Wendrowski 1 of 9, #18 Exhibit Letter Wendrowski 2 of 9, #19 Exhibit Letter Wendrowski 3 of 9, #20 Exhibit Letter Wendrowski 4 of 9, #21 Exhibit Letter Wendrowski 5 of 9, #22 Exhibit Letter Wendrowski 6 of 9, #23 Exhibit Letter Wendrowski 7 of 9, #24 Exhibit Letter Wendrowski 8 of 9, #25 Exhibit Letter Wendrowski 9 of 9, #26 Exhibit Affidavit Bix Ellenbecker, #27 Exhibit Unsigned Order to Show Cause, #28 Exhibit Request of Judicial Intervention, #29 Exhibit Order to Show Cause, #30 Exhibit Affidavit of Service).(Melchionna, Luca) Modified on 5/12/2022 (vf). |
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